Revolutionary Information

Every router, camera and smart plug sold in the United States should be legally required to carry a password unique to that unit, or make you set your own, before it touches your Wi-Fi. Britain has enforced exactly that default password ban since 29 April 2024. America chose a sticker. The standard objection says a voluntary label lets shoppers reward careful makers without Washington writing firmware rules. It sounds reasonable, until you see what the sticker has done since.

Why a default password ban beats a label

A ban beats a label because it protects the buyer who never reads packaging, never registers the device and never changes a setting, while a label protects only the shopper who already knows to look for it.

The British version, set out on GOV.UK's product security regime page, is blunt: passwords must be unique per product or set by the user. Makers must also publish a route for reporting security bugs and say how long they will ship security updates. A British buyer gets that protection without knowing the law exists, which is the whole point of a rule.

America took the other road. The FCC approved the US Cyber Trust Mark on 14 March 2024 as a voluntary label, CyberScoop reported, so a US shopper gets password protection only when a maker opts in. Its lead administrator, UL Solutions, then withdrew on 19 December 2025 amid an FCC probe into its China ties, says Cybersecurity Dive. The FCC named the ioXt Alliance in its place on 13 April 2026, Broadband Breakfast reported, and won't pay for the job. By my count, the label shoppers were told to trust sat with nobody in charge for nearly four months.

Washington has been here before: its memory safety roadmap deadline for critical-infrastructure software carried no penalty and passed quietly. Europe binds vendors instead, as the Cyber Resilience Act's 24-hour vulnerability warning shows. Four figures from GOV.UK, the PSTI Act 2022 and Broadband Breakfast show the gap.

A fine pegged to worldwide turnover is too big for a global router brand to treat as a cost of selling in Britain, so the cheap answer is one firmware build for every market. You just can't tell from a US box which makers did it.

Does the UK ban default passwords on smart devices?

Yes, the UK has banned universal default passwords on consumer connected devices since 29 April 2024, requiring each product to ship with a unique password or make the buyer set one, under the Product Security and Telecommunications Infrastructure regime.

The table sets that law against the US label, read as a buyer standing in a store.

Read down the right-hand column: the label helps only buyers who already do the work. The first-row fine comes from the PSTI Act 2022; the 115-day gap is my arithmetic from the reported dates above.

Do routers have to come with unique passwords?

Only in some places: in Britain since April 2024, in California and Oregon since 2020, and across the EU from December 2027, while a router sold in the other 48 US states can still legally share one factory password.

California's SB-327, operative since 1 January 2020 (as of 2020), demands a password "unique to each device manufactured" or one the user creates. Oregon passed a near-copy. The EU's Cyber Resilience Act, on EUR-Lex, requires a secure by default configuration once its main obligations apply on 11 December 2027. So the "too costly" objection collapses: the engineering exists, and the biggest US state has demanded it for years.

The second objection calls default passwords a niche consumer worry. CISA disagrees. In December 2023 (as of 2023) its Secure by Design alert urged makers to drop default passwords after attackers reached Unitronics controllers at US water facilities; CyberScoop reported their factory password was 1111, so one shared login opened every identical unit. The federal security agency called it a manufacturer failure in writing, then only asked nicely. As with post-quantum migration deadlines, guidance without teeth moves at the pace of the slowest vendor.

One grey area remains, and this is opinion: should a federal rule reach devices already in homes? I'd cover new sales only, because retroactive rules invite lawsuits that stall everything. Watch-outs meanwhile:

• A Cyber Trust Mark helps, but its absence proves nothing.
• An app-based setup can leave the local web login on its factory value.
• Marketplace imports may follow no national rule.

So here's the decision. If you're in the US, treat the label as a bonus and the password check above as the real test, and this week log in to your own router and replace any password printed in its manual. Then tell your representative that Britain already proved the rule costs makers almost nothing.

Here is the rule. Under the Product Security Bad Practices guidance from CISA and the FBI, a maker of software used in critical infrastructure that had no published memory safety roadmap by January 1, 2026 is, in the agencies' own word, "dangerous". The date came and went. Your firewall vendor, your hospital's imaging supplier, the firm behind your water utility's control panels: none of them owed you a thing when it passed.

The flaw is in the rule. The same document says it "is non-binding" and "imposes no requirement", so the risk of a missing plan sits with you, the customer. It should be compulsory. And the standard objection, that leaving C and C++ is too slow and too costly, no longer survives the data.

Is CISA's memory safety guidance mandatory?

No, CISA's memory safety guidance is voluntary: the agencies call a missing roadmap dangerous for critical-infrastructure software, but attach no fine and no procurement ban, so a vendor that ignored the January 2026 date faces nothing.

Washington has stayed in that register. A June 2025 NSA and CISA information sheet on memory safe languages (Rust, Go and others that stop code touching memory it does not own) says the agencies "urge organizations to consider whether adopting MSLs is practical for their circumstances." That hands every vendor two exits, "consider" and "practical". A buyer waiting for a federal push is waiting for something the government has said, in writing, it will not do.

Other regulators have been less shy. Europe wrote vulnerability handling into law, down to the 24-hour exploited-vulnerability warning the Cyber Resilience Act demands. Even NIST put calendar years on its post-quantum migration deadlines. Memory safety, the older and better-understood problem, got an adjective.

Is Rust really safer than C++?

Yes, by a margin that ends the argument. A November 2025 Google report, Rust in Android, found its roughly 5 million lines of Rust running at about 0.2 memory-safety vulnerabilities per million lines, against roughly 1,000 in its C and C++, a reduction Google puts at more than 1,000x. That kills the excuse that safer languages just move bugs elsewhere.

But the objection was always about cost: rewriting slows teams, and ship dates pay salaries. Four numbers test that. Google's Android data supplies two, measured on changes of comparable size. MITRE's CWE Top 25, released in December 2025, supplies a count of memory errors among the most dangerous weaknesses. The calendar supplies the last.

Show the rollback figure to a sceptical finance director. A rollback is a release pulled after shipping, usually an outage and a lost weekend. Fewer of those means the cost objection runs backwards.

With no regulator compelling a plan, your contract is the only lever left.

What a required memory safety roadmap changes for buyers

Requiring the plan turns a vendor's vague intention into a dated, auditable commitment that covers its riskiest code first, which gives a buyer something to enforce at renewal instead of a hope.

The flaw-rate row is my arithmetic, not Google's: Android's measured densities scaled to a 100,000-line component. At those rates a new C++ service carries latent memory flaws in triple figures, and the Rust version most likely none.

Where a compulsory roadmap gets hard

A compulsory plan gets hard in two places: products close to retirement, which the guidance already exempts, and vendors who publish a roadmap with no dates in it, which satisfies the letter while changing nothing.

Do software makers have to stop using C and C++ by 2026?

No. The CISA and FBI guidance asks existing products for a plan, not a rewrite, and only calls new critical-infrastructure product lines in C or C++ dangerous where a memory-safe alternative exists. I'd go further than CISA, or at least put it more bluntly: a roadmap without a year beside each component is a brochure.

The unresolved question, in my opinion, is embedded firmware. A substation controller will not be rewritten, and a plan for it may mean little beyond the next model. Newer guidance shares the gap, such as the NSA's May 2026 advisory on MCP security for AI agents: sound advice, no teeth. Watch for:

• Goals with no year per component.
• Memory-safe claims covering only new features.
• An end-of-support date just inside the exemption.
• Sandboxing sold as a substitute, not a stopgap.

If two of those are true, stop waiting for Washington. This week, email the vendor asking for its published plan and support end date, and tell procurement that renewal now depends on a dated commitment, cryptographic code first. Require it yourself, because nobody else will.

Here is the rule. Since 11 September 2026, any company selling software or connected hardware in the European Union that learns one of its products is being actively exploited has 24 hours to send an early warning to the authorities, and 72 hours to follow it with a full notification. That is CRA reporting, set out in the European Commission's guidance on the Cyber Resilience Act, and it is already live. A vendor in Austin that sells the same router in Berlin and Boston now owes Berlin a warning. Boston gets nothing.

That gap should close by law, and the usual objection is mostly answered by how the rule is written.

Why CRA reporting should be the global floor

A vendor knows first when its product is being exploited, so the duty to warn belongs with the vendor, and a rule that protects only EU customers leaves every other buyer of the same product exposed.

The manufacturer sees the crash reports, the researcher emails and the telemetry spike days before customers notice anything. The Act makes that knowledge travel: manufacturers must also inform impacted users, according to Hogan Lovells' 11 September 2026 briefing. An EU hospital running a VPN appliance gets told. A clinic in Ohio running the identical box does not.

The American answer is thinner. CIRCIA puts the reporting duty on critical-infrastructure operators, the victims, not on the vendor whose code let the attacker in. CISA's Secure by Design pledge is voluntary, so a US buyer holds no enforceable promise unless it sits in the contract. Treating a pledge as a rule is outdated advice.

Anyone who tracked the DPDP consent manager deadline in India or post-quantum migration deadlines under NIST IR 8547 knows the pattern: a regulator sets a clock, and vendors discover how little of their process was built for one.

Run the clock on a real calendar. Confirm exploitation at 5pm on a Friday and the early warning is due by 5pm Saturday, the full notification by 5pm Monday. That is our own arithmetic, and it means someone with authority to file must be reachable all weekend. The four numbers below, from the Commission and Article 64 of the Act, decide whether vendors take that seriously.

The revenue-linked ceiling is what changes behaviour at large vendors. A flat cap is a budget line; a share of global revenue grows with the company, so the suppliers in the most networks carry the steepest exposure.

Does the Cyber Resilience Act apply to US companies?

Yes, the Cyber Resilience Act applies to any manufacturer placing products on the EU market, wherever it is based, so a US vendor selling into Europe already owes EU buyers warnings its home customers never receive.

US figures below come from Ballard Spahr's Byte Back analysis of CIRCIA (February 2026) and CISA's pledge page.

The vendor builds the triage desk for Europe anyway, so American customers pay for output they never see. Vendors treating 2027 as the start date have the calendar wrong.

Won't a 24-hour rule crush small vendors?

No, because the 24-hour step is an early warning to a national security team, not a public disclosure or a finished report, and the fuller detail follows on a structured, longer schedule.

At its strongest, the objection says a ten-person firm has no security team and a panicked filing could leak. Filings go through ENISA's Single Reporting Platform to the CSIRT of the manufacturer's main establishment, so the warning never touches the open internet. Attackers learn nothing from a message they cannot read.

The burden is real but scoped: a written threshold for "actively exploited" and a named Sunday filer. Plus a rehearsal. Two, honestly, because the first always finds the gap nobody wrote down. AI tooling vendors have more ground to cover, with flaws surfacing in MCP servers flagged in the NSA's advisory and in AI agent credentials nobody has inventoried.

The genuine grey area is the word "aware". In our view the clock should start at credible evidence of exploitation, not legal sign-off, but enforcement will settle it. Watch for these:

• Community-maintained components sit outside the clock until open-source stewards join.
• Severe incidents run a different final-report schedule, so check which your contract names.
• US buyers hold no right to the EU notice, even for identical firmware.

Do not wait for Washington. This week, pull your three largest software contracts and add one clause: the vendor notifies you within 24 hours of confirming active exploitation, on the same terms it already owes EU regulators. A vendor that refuses a promise it already keeps in Europe has told you what you need to know.

Related: why a memory safety roadmap should be compulsory for software vendors

Related: why a compulsory default password ban beats a voluntary label